NSR Litigation and Reform: An Introduction to the Topic

The New Source Review (NSR) rule has recently been
the subject of considerable judicial, regulatory, and
media attention. This month, EM presents a series of
articles that focus on NSR. In the first article, Debra Jezouit1
summarizes several recent developments relating to the NSR
rule. This is followed by four2-5 stakeholder groups’ perspectives
on these issues.

Introduced by the U.S. Environmental Protection Agency
(EPA) in the 1970s, the NSR rule under the Clean Air Act (CAA)
is a preconstruction permitting program that governs air pollutant
emissions from new and existing industrial sources that
undergo “major modifications.” If determined to be applicable,
the NSR rule mandates the installation of Best Available Control
Technology (BACT) or Lowest Achievable Emission Rate
(LAER), depending on whether the source is located in
an “attainment” or “nonattainment” area (relating to
National Ambient Air Quality Standards [NAAQS] area designations),
respectively. The NSR program has worked well in
the case of permitting new industrial sources. With respect to
existing sources, however, NSR remains a complex, confusing,
and controversial regulatory program. Much of the controversy
concerns the exclusion from the rule of emissions associated
with “routine maintenance, repair, and replacement”
(RMRR) activities and analyses of emission changes before and
after modifications that determine NSR applicability.

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